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International taxes
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INTERNATIONAL TAXES
International review for April 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
Self's assessment: signs of a ceasefire in the digital trade war?
Heather Self
In our continuing series, Heather Self reviews tax issues that make the headlines in the national press. This week, the impact of the new US proposals on international tax reform.
Finance Bill 2021: hybrid mismatch rules version 2.0
Claudine Fox
Nick Evans
The UK hybrid rules impose double taxation as currently enacted, explain
Nick Evans and Claudine Fox (Baker McKenzie). Changes will be made, but
do they go far enough?
International holding structures: are they structurally sound?
Creina Kane
Jenni Bullivant
Aaron Mehta
Jenni Bullivant, Creina Kane and Aaron Mehta (PwC) reflect on the host of international tax issues and complexities associated with international holding structures as a consequence of the continually changing external landscape.
International review for March 2021
Tim Sarson
Tim Sarson (KPMG) reviews recent overseas developments, including a significant breakthrough on public country by country reporting.
The European Commission’s ‘digital levy’
Jennifer Maskell
Richard Sultman
The European Commission has a new ‘digital levy’ initiative, pending
international consensus on digital taxation. Jennifer Maskell and Richard
Sultman (Cleary Gottlieb Steen & Hamilton) consider how it might look.
International review for February 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
International tax and treasury issues in 2021
Andrew Cotterill
John Webb
Mairead Murphy
Interest deductibility, foreign exchange, withholding taxes... John Webb,
Andrew Cotterill and Mairead Murphy (PwC) review the key UK tax
considerations for financing transactions and global treasury functions.
Brexit: tax competition between the UK and the EU27
David Haworth
Alison Dickie
Alison Dickie and David Haworth (Freshfields Bruckhaus Deringer)
consider whether the Brexit deal paves the way for a low-tax and less regulated
UK tax environment.
International tax cooperation with the EU post-Brexit
Jason Collins
Catherine Robins
Now that the Brexit transition period has ended, where does this leave the
UK’s administrative cooperation with other jursidictions, ask Jason Collins
and Catherine Robins (Pinsent Masons).
Go to page
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214
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way